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4AO 106 (Rev. 06/09) Application for a Search Warrant 
5UNITED STATES DISTRICT COURT 
6for the 
7Southern District of New York 
8In the Matter of the Search of 
9(Briefly describe the property to be searched 
10or idéntifr the person by name and address) 
11Four Premises and TWO Electronic Devices, See 
12Attached Affidavit and Riders 
13MAG 
142969 
15APPLICATION FOR A SEARCH WARRANT 
16I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under 
17penalty of perjury that I have reason to believe that on the following person or property (identify theperson or describe the 
18P See Attached Affidavit and Riders 
19District of 
20Southern 
21located in the 
22person or describe the property to bé seized): 
23PLEASE SEE ATTACHED AFFIDAVIT AND RIDERS. 
24New York 
25, there is now concealed (identify the 
26The basis for the search under Fed. R. Crim. P. 41 (c) is (check one or more): 
27evidence of a crime; 
28contraband, fruits of crime, or other items illegally possessed; 
29property designed for use, intended for use, or used in committing a crime; 
30O a person to be arrested or a person who is unlawfully restrained. 
31The search is related to a violation of: 
32Offense Description 
33Code Section 
3418 U.S.C. s 371, 1005, 1014, Conspiracy, false bank entries, false statements to a financial institution, 
35wire fraud, bank fraud, and 
361343 and 1344, and 
37illegal campaign contributions 
3852 USC 30116 and 30109 
39The application is based on these facts: 
40PLEASE SEE ATTACHED AFFIDAVIT AND RIDER. 
41Continued on the attached sheet. 
42days (give exact ending date if more than 30 days: 
43O Delayed notice of 
44under 18 U.S.C. 3103a, the basis of which is set forth on the attached sheet. 
45) is requested 
46Sworn to before me and signed in my presence. 
47Date: 
4804/08/2018 
49City and state: 
50Printed name nard title 
51Judge 'S signature 
52Hon. Henry. B. Pitman, IJ.S. Magistrate Judge 
53Printed name and title 
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57UNITED STATES DISTRICT COURT 
58SOUTHERN DISTRICT OF NEW YORK 
59In the Matter of the Application of the United 
60States of America for a Search and Seizure 
61Warrant for the Premises Known and Described 
62as (1) 502 Park Avenue, 
63York, New York 10022, (2) Michael Cohen's 
64Office at 30 Rockefeller Plaza, 23rd Floor, New 
65York, New York 10112, (3) Safe Deposit Box # 
66Located at the TD Bank Branch at 500 Park 
67Avenue, New York, New York 10019, and (4) 
68Inews 
691728, New York, New York 10065, and Any 
70Closed Containers/ltems Contained Therein, and 
71the Electronic Devices Known and Described as 
72(1) an Apple iPhone with Phone Number 
73— and (2) an Apple iPhone with Phone 
74Number 
75Reference No. 2018R00127 
76SOUTHERN DISTRICT OF NEW YORK) ss.•. 
77TO BE FILED UNDER SEAL 
78Agent Affidavit in Support of 
79Application for Search and Seizure 
80Warrant 
81Special Agent, Federal Bureau of Investigation, being duly sworn, 
82deposes and says: 
83I. Introduction 
84A. Affiant 
85I am a Special Agent with the Federal Bureau of Investigation ("FBI"). I have been 
861. 
87a Special Agent with the FBI since 2009. In the course of my experience and training in these 
88positions, I have participated in criminal investigations into federal offenses involving a wide array 
89of financial crimes, including frauds on financial institutions, as well as into offenses involving 
90public corruption. I also have training and experience executing search warrants, including those 
91involving electronic evidence. 
92I make this Affidavit in support of an application pursuant to Rule 41 of the Federal 
932. 
94Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject 
952 
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100Premises") and the electronic devices specified below (the "Subject Devices") for, and to seize, 
101the items and information described in Attachments A, B, C, D, E and F. This affidavit is based 
102upon my personal knowledge; my review ofdocuments and other evidence; my conversations with 
103other law enforcement personnel; and my training, experience and advice received concerning the 
104use of electronic devices in criminal activity and the forensic analysis of electronically stored 
105information ("ESI"). Because this affidavit is being submitted for the limited purpose of 
106establishing-probablecause, it-doesnotinclude-all-the:facts-thatl have learned during-the-course= 
107of my investigation. Where the contents of documents and the actions, statements, and 
108conversations ofothers are reported herein, they are reported in substance and in part, except where 
109otherwise indicated. 
110B. The Subject Premises and Subject Devices 
111Subject Premises-I, Subject Premises-2, Subject Premises-3 and Subject Premises- 
1123. 
1134 (collectively, the "Subject Premises") are particularly described as: 
114located inside the building at 502 
115Subject Premises-I is Apartment 
116a. 
117Park Avenue, New York, New York 10022. The building located at 502 Park Avenue is a 32- 
118floor of the building. 
119floor brick residential building. Subject Premises-I is located on the 
120Based on my review of New York City property records, I have learned that Michael Cohen and 
121Laura Cohen own Subject Premises-1.1 Additionally, as described below, Subject Premises-I is 
122Cohen's full-time residence. 
123Subject Premises-2 is an offce located on the 23rd floor of the building at 
124b. 
12530 Rockefeller Plaza, New York, New York 10112. The building located at 30 Rockefeller Plaza 
126I As noted infra, I have learned that on or about October 28, 2015, Cohen transferred Subject 
127Premises-I into a trust. 
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133is a 66-floor office building that spans the entire block between Sixth Avenue and Rockefeller 
134Plaza. Subject Premises-2 is located on the 23rd floor of the building inside of the offices of the 
135law firm Squire Patton Boggs. The office is assigned to Michael Cohen. As described below, 
136Michael Cohen works and conducts meetings at Subject Premises-2. 
137Subject Premises-3 is a safety deposit box located inside the TD Bank 
138c. 
139branch location at 500 Park Avenue, New York, New York 10019. Based on my review ofrecords 
140¯¯maintained learned that-the-safety-deposit box is approximately-five inchesby 
141The safety deposit box is in the name of Michael 
142ten inches in size, and is marked as box 
143Cohen and Laura Cohen. 
144Subject Premises-4 is Room 1728 located inside the Loews Regency Hotel 
145d. 
146at 540 Park Avenue, New York, New York 10065. The building is a luxury hotel located on Park 
147Avenue and 61st Street. Subject Premises-4 is located on the 17th floor of the hotel. Based on my 
148review of emails obtained pursuant to search warrants described below, I have learned that on or 
149about January 5, 2018, Cohen received an email from an employee of Loews Regency, which 
150included a price quote for a long-term stay suite based on a three-month stay from January 8 to 
151April 8, 2018.2 On or about January 29, 2018, Cohen sent an email to a Loews Regency employee, 
152stating, in pertinent part: "I just spoke to my wife and she has scheduled the move for Thursday. 
153Please mark down that we will be taking possession on Thursday, February 1st." Based on my 
154leview of cell phone location data, I have learned that, over the past 24 hours, two cellular phones 
155used by Cohen have been located in the vicinity of Subject Premises-4. In particular, on or about 
1562 Although the quoted price contemplated a three-month stay from January 8 to April 8, it appears 
157that Cohen did not move in until February 1, and as of today, April 8, cellphone location 
158information demonstrates that Cohen's cellular phones are in still in the vicinity of Subject 
159Premises-4. 
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165April 8, 2018, law enforcement agents using a "triggerfish" device identified Room 1728 as the 
166room within the hotel in which the Subject Devices are most likely present.3 
167e. 
168Premises-4. 
169Therefore, I believe that Cohen is temporarily residing in Subject 
170Subject Device-I and Subject Device-2 (collectively, the "Subject Devices") are 
1714. 
172particularly described as: 
173Subject Device—1äs-an-Apple-iPhoneserviced by-A-T-&-T-with the-telephone 
174Based on my review of records maintained by AT&T, I have learned that Subject 
175Device-I is subscribed to Michael Cohen. Based on my review ofcellphone location information 
176maintained by AT&T, I have learned that Subject Device-I is presently located in the Southern 
177District of New York. 
178b. SubjectDevice-2 is an Apple iPhone serviced by AT&Twiththetelephonenumber 
179Based on my review of records maintained by AT&T, I have learned that Subject 
180Device-2 is subscribed to Michael Cohen. Based on my review of cellphone location information 
181maintained by AT&T, I have learned that Subject Device-2 is presently located in the Southem 
182District of New York. 
183c. Based on my training, experience, and research, and from consulting the 
184manufacturer's and service providers' advertisements and product technical specifications 
185available online, I know that the Subject Devices have capabilities that allow them to, among other 
186things: make and receive telephone calls; save and store contact information; send and receive 
1873 Based on my conversations with these agents, I understand that it is also possible that the Subject 
188Devices are one floor below, in Room 1628. However, as noted, I understand that Cohen received 
189a price quote for a long-term stay suite and is residing there with his family. Based on my 
190conversations with FBI agents conducting surveillance, I understand that Room 1728 appears to 
191be a suite, whereas Room 1628 appears to be a standard room. 
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197emails and text messages; download and run mobile telephone applications, including encrypted 
198call and messaging application such as WhatsApp, Signal, and Dust; take, send, and receive 
199pictures and videos; save and store notes and passwords; and store documents. 
200C. The Subject Offenses 
201For the reasons detailed below, I believe that there is probable cause to believe that 
2025. 
203the Subject Premises and Subject Devices contain evidence, fruits, and instrumentalities of 
204institution), 1343 (wire fraud), and 1344 (bank fraud) (collectively, the "Bank Fraud Offenses"), 
20552 U.S.C. 30116(a)(1)(A) and 30109(d)(1)(A)(1) (illegal campaign contributions) (the 
206"Campaign Finance Offenses"), and 18 U.S.C. 371 (conspiracy as it pertains to the other 
207Subject Offenses) (collectively, the "Subject Offenses"). 
208D. Prior Applications 
2096. The FBI and the United States Attomey's Office for the Southern District of New 
210York ("USAO") have been investigating several courses of criminal conduct by Michael Cohen. 
211Cohen is an attorney who currently holds himselfout as the personal attomey for President Donald 
212Trump, and who previously served for over a decade as an executive in the Trump Organization, 
213an international conglomerate with real estate and other holdings. 
214In connection with an investigation then being conducted by the Office of the 
2157. 
216Special Counsel ("SCO"), the FBI sought and obtained from the Honorable Beryl A. Howell, Chief 
217United States District Judge for the District of Columbia, three search warrants for emails and 
218other content information associated with two email accounts used by Cohen, and one search 
219warrant for stored content associated with an iCloud account used by Cohen. Specifically: 
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225a. 
226On or about July 18, 2017, the FBI sought and obtained a search warrant for 
227(the "Cohen Gmail Account") sent or received 
228emails in the account 
229between January 1, 2016 and July 18, 2017 (the "First Cohen Gmail Warrant"). 
230b. On or about August 8, 2017, the FBI sought and obtained a search warrant 
231for content stored in the iCloud account associated with Apple ID —@gmail.com (the 
232"Cohen iCloud Accounf' and the "Cohen iCloud Warrant"). 
233the-FBI-sought-and-obtained—a-search 
234c. 
235warrant for emails in the Cohen Gmail Account sent or received between June 1, 2015 and 
236November 13, 2017 (the "Second Cohen Gmail Warrant"). 
237d. On or about November 13, 2017, the FBI sought and obtained a search 
238warrant for emails in the account (the "Cohen MDCPC Account") sent or 
239received between the opening ofthe Cohen MDCPC Account4 and November 13, 2017 (the "First 
240Cohen MDCPC WatTant"). 
2418. The SCO has since referred certain aspects of its investigation into Cohen to the 
242USAO, which is working with the FBI's New York Field Office. As part of that referral, on or 
243about February 8, 2018, the SCO provided the USAO with all non-privileged emails and other 
244content information obtained pursuant to the First Cohen Gmail Warrant, Second Cohen Gmail 
245Warrant, and Cohen MDCPC Warrant. On or about March 7, 2018, the SCO provided the USAO 
2464 Based on my review of this warrant and the affidavit in support of it, I know that the warrant did 
247not specify a time period, but the affidavit indicated that, pursuant to court order, the service 
248provider had provided non-content information for the Cohen MDCPC Account that indicated that 
249the account contained emails from the approximate period of March 2017 through the date of the 
250warrant. 
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256with all non-privileged content obtained pursuant to the Cohen iCloud Warrant.5 A filter team 
257working with the SCO had previously reviewed the content produced pursuant to these warrants 
258for privilege. 
259On or about February 28, 2018, the USAO sought and obtained search warrants for 
2609. 
261emails in the Cohen Gmail Account and the Cohen MDCPC Account, among other accounts, sent 
262or received between November 14, 2017 and February 28, 2018 (the "Third Cohen Gmail Warrant" 
263aridfthe- "S econd-Cöhen 
264subject to an ongoing review for privilege by an SDNY filter team.6 
26510. The emails search warrants described above are referred to collectively as the 
266"Cohen Email Warrants." 
26711. On or about April 7, 2018, the USAO and FBI sought and obtained a warrant for 
268prospective and historical cellphone location information for Subject Device-I and Subject 
269Device-2. On or about April 8, 2018, the USAO and FBI sought and obtained authority to employ 
270an electronic technique, commonly known as a "triggerfish," to determine the location of Subject 
271Device-I and Subject Device-2. 
272II. Probable Cause 
273A. Overview 
27412. The United States Attorney's Office for the Southern District of New York and FBI 
275are investigating, among other things, schemes by Target Subject Michael Cohen (a) to defraud 
276multiple banks from in or about 2016 up to and including the present, and (b) to make an illegal 
2775 The SCO had previously provided a subset of this non-privileged content on or about February 
2782, 2018. 
2796 On or about February 28, 2018 and April 7, 2018, the USAO and FBI sought and obtained Rule 
28041 search warrants authorizing the search of emails and content obtained pursuant to previously 
281issued warrants for additional subject offenses. 
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287campaign contribution in October 2016 to then-presidential candidate Donald Trump. As noted, 
288Cohen is an attomey who currently holds himself out as the personal attorney for President Donald 
289Trump, and who previously served for over a decade as an executive in the Trump Organization, 
290an international conglomerate with real estate and other holdings. 
29113. The investigation has revealed that Cohen has made affirmative misrepresentations 
292in and omitted material information from financial statements and other disclosures that Cohen 
293-vrovided a—transaction—intended—to—relieve—Cohen of 
294approximately $22 million in debt he owed on taxi medallion loans from the banks. As set forth 
295in detail below, in these financial statements, and in his oral and other written statements to these 
296banks, Cohen appears to have (i) intentionally misrepresented his ability to pay cash by failing to 
297disclose cash he began leceiving in 2017 from new consulting work; (ii) significantly understated 
298his total holdings of cash and cash equivalents; (iii) failed to disclose tens of thousands of dollars 
299he received in monthly interest income, and (iv) failed to inform the banks from which he was 
300seeking debt relief that he had agreed to make a $3.8 million cash payment to a third party,— 
301in connection with 
302lcquisition ofthe taxi medallions securing Cohen's 
303debt. By making these misrepresentations and material omissions, Cohen avoided making 
304monthly payments on his loans, and attempted to fraudulently induce the banks to relieve him of 
305certain repayment obligations and personal guarantees that Cohen and his wife had signed. 
30614. Additionally, the investigation has revealed that shortly before the 2016 
307presidential election, Cohen made a payment of $130,000 from a limited liability corporation 
308("LLC") to Stephanie Clifford, an individual who is alleged to have had an extramarital affair with 
309then-candidate Trump. This payment was made to Clifford in exchange for an agreement not to 
310make any public disclosures about her alleged affair with Trump. As set forth below, there is 
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316probable cause to believe that Cohen made this payment to Clifford for the purpose of influencing 
317the presidential election, and therefore that the payment was an excessive in-kind contribution to 
318the Trump campaign. 
31915. Based on my review of emails obtained from the Cohen Email Warrants, 
320information obtained pursuant to the iCloud Warrant, and documents produced pursuant to 
321subpoenas, as well as my review of public sources, I have learned that Cohen has used the Subject 
322Premises to (a) receive-documents-related-to-the-transactionintended-to relieve Cohen of-his-taxi 
323medallion debt, (b) receive documents and/or conduct meetings related to his consulting work, (c) 
324receive documents and/or conduct meetings relating to his finances and assets, some of which, as 
325noted above and as detailed further herein, he has concealed from the banks in connection with the 
326refinancing of his taxi medallion debt, (d) receive and send documents relating to his payment to 
327Clifford, and (e) house and operate electronic devices that were utilized in connection with, among 
328other things, the taxi medallion transaction, Cohen' s consulting work, and his payment to Clifford. 
329Specifically, as described below, Subject Premises-I likely contains evidence concerning Cohen's 
330taxi medallion loans, his negotiations with banks, his personal finances, his consulting work, his 
331tax returns, and his payment to Clifford, as well as electronic devices containing such evidence, 
332all of which constitute or contain evidence of the Subject Offenses. Additionally, as described 
333below, Subject Premises-2 likely contains evidence relating to Cohen's consulting work, his 
334finances, and his payment to Clifford, as well as electronic devices containing such evidence. 
335Subject Premises-3, as described below, likely contains evidence relating to Cohen's assets and 
336finances, including assets that may not have been disclosed to banks in connection with the 
337refinancing of Cohen's taxi medallion debt or documents relating to such assets, and documents 
338or evidence related to Cohen's payment to Clifford. Subject Premises-4 likely contains electronic 
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344devices, including Subject Device-I and Subject Device-2, which themselves contain evidence of 
345the Subject Offenses, including concerning Cohen's taxi medallion loans, his negotiations with 
346banks, his personal finances, his consulting work, his tax returns, and his payment to Clifford. 
347Accordingly, and as set f01th in more detail below, there is probable cause to believe that the 
348Subject Premises and Subject Devices will include evidence of the Subject Offenses. 
349B. Probable Cause Regarding Subjects' Commission of the Subject Offenses7 
350The Bank-Fraud-Scheme 
351(i) Cohen's Statements to Sterling National Bank 
35216. As set forth in detail below, in 2014, Cohen, through LLCs controlled by him and 
353his wife, Laura Cohen, entered into a series ofloans from Sterling National Bank ("Sterling") and 
354the Melrose Credit Union ("Melrose"), secured by taxi medallions, for approximately $20 million. 
355Though entered into by LLCs, the loans were also secured by personal guarantees in the names of 
356both Cohen and his wife. Over time, as the taxi industry weakened and the medallions lost value, 
357Cohen sought to renegotiate the terms of those loans and/or relieve himself from their obligations, 
358including the personal guarantees. As part of that effort, Cohen made a series of representations 
359to Sterling and Melrose about his net worth, assets, available cash and income, among other things. 
360Specifically, based on my review of records maintained by Sterling and Melrose, and public 
361sources concerning the taxi industry and the value of taxi medallions, as well as my participation 
362in interviews with a Sterling executive vice-president (the "Sterling Employee-I") and two other 
3637 In the following recitation of probable cause, I frequently refer to phone calls or text messages 
364involving Cohen. The text messages described herein as sent or received by Cohen were all sent 
365or received from the telephone numbers associated with Subject Device-I or Subject Device-2. 
366The vast majority of the phone calls described herein made or received by Cohen were made or 
367received by the telephone numbers associated with Subject Device-I or Subject Device-2, although 
368in cenain limited instances Cohen used a landline or other phone. 
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374Sterling employees ("Sterling Employee-2" and "Sterling Employee-3"), I have learned, among 
375other things, the following: 
376a. Taxi medallions are small metal plaques affixed to taxis. Without a medallion, it 
377is illegal to operate a taxi in cities with medallion systems, such as New York City. Cohen and his 
378wife own multiple LLCs that collectively own 32 taxi medallions (each LLC owns two 
379medallions).8 Cohen's purchase of these New York taxi medallions was originally financed by 
380loans from Capital One-bank, for 
381operator, and leased his medallions to a third party. That third party made monthly payments to 
382Cohen, who in tum used some of those proceeds to make his monthly loan payments to Capital 
383One. 
384b. In early 2014, Cohen became a customer of Sterling when he sought to refinance a 
385mortgage on a rental property that he owned. In or around April 2014, Cohen raised with Sterling 
386the prospect ofrefinancing his taxi medallion loans, which were then at Capital One. By in or about 
387September 2014, Cohen began negotiating a lending transaction with Sterling that would allow 
388Cohen to pay off his loans at Capital One and borrow more money from the then-increase in value 
389of the medallions. According to Sterling Employee-I, in 2014, prior to the recent upheaval in the 
390taxi industry—as a result of the emergence of ride-sharing services, such as Uber—taxi medallion 
391loans were viewed by banks and investors as safe, short term credits, as the market value of taxi 
392medallions was consistently rising. Consequently, taxi medallion loans—like the loans held by 
393Cohen—were frequently refinanced at increasing amounts as the value of the medallions rose. 
394According to Sterling Employee-I, borrowers typically cashed out the increase in the loan amount 
3958 One of these companies, Mad Dog Cab Corp., was jointly owned by Sondra Cohen, who I 
396believe is Cohen's mother. 
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402and used the additional funds for other purposes. Cohen appears to have followed this approach in 
4032014, when he agreed to refinance his medallion loans for approximately $22 million, which— 
404according to letters from Capital One in Sterling's files—was greater than his previous debt at 
405Capital One Bank ($21 million, of which $14.6 million was a line ofcredit to Cohen). This allowed 
406Cohen to cash out the proceeds from the transaction. 
407c. Based on my review of records maintained by Sterling, I have learned that on or 
408about December 8,-2014ßach-ofCohen's-sixteen taxi-medallion-LLCs entered intoloan agreements 
409and promissory notes with Sterling for the principal sum of $1,375,000, with repayment due on 
410December 8, 2016. Each loan was signed by Michael or Laura Cohen, depending on who was the 
411sole shareholder of the LLC. The address listed for each of the LLCs was the address for Subject 
412Premises-I. The loans were also each secured by a security agreement, dated the same day, making 
413the medallions collateral for the notes. To give Sterling additional security, Michael and Laura 
414Cohen signed personal guarantees and confessions of judgment, giving Sterling the right to pursue 
415collection against the Cohens' personal assets were their corporations to default under the loan 
416agreements. The personal guaranty agreements stated that the LLCs had offices at the address for 
417Subject Premises-I, and contained a notice provision that stated that any notices required by the 
418agreements should be mailed to Subject Premises-I. In total, Sterling agreed to lend approximately 
419$22 million to the Cohens' companies. 
420d. Pursuant to participation agreements, Sterling transferred 45 percent of Cohen's 
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422taxi medallion debt to Melrose. 
4239 Melrose, which had a business principally focused on taxi medallion loans, is now in 
424conservatorship by the National Credit Union Administration ("NCUA"). 
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430e. In evaluating Cohen's requested refinancing of the taxi medallions, Sterling (and 
431Melrose, consistent with its participation in the deal) conducted due diligence. At Sterling's 
432request, Cohen provided Sterling with a statement of financial condition, dated August 1, 2014 
433(the "August 2014 Financial Statement"), which indicated that Cohen had $100,740,000 in total 
434assets, $23,550,000 in total liabilities, and a net worth of $77,190,000.10 From my review of a 
435Sterling credit memorandum, dated September 29, 2014, I know that Sterling viewed the 
436transaction favorablybecause,-æecountmgfor-loampayments, cash-flowsåom the medallions-were— 
437projected to be positive, the value of the collateral (as estimated by Sterling) exceeded $42 million, 
438and the net worth of Cohen—who was the direct obligor under the guarantee agreements—was 
439over $77 million. An internal Sterling credit and risk rating analysis report, dated October 20, 
4402014, recommended approval of the loans for substantially the same reasons. 
441f. Based on my review of records maintained by Sterling and public sources, I have 
442learned that over time, the collateral backing Cohen's loans (taxi medallions) lessened in value due 
443to the rise in ride-sharing companies. Additionally, Cohen began falling behind on loan payments 
444to Sterling and Melrose. I know from records maintained by Sterling and an interview with Sterling 
445Employee-2 that, beginning in or around September 2015, Cohen told Sterling, in sum and 
446substance, that the individual leasing Cohen's medallions had fallen behind in making payments to 
447Cohen, and that as a result, the monthly cash flow from his taxi medallions had been reduced, 
448leaving him with a shortfall of approximately $16,000 each month. For instance, I have reviewed 
449an email from Sterling Employee-2, dated September 9, 2015, summarizing a call with Cohen— 
450which according to the email and toll records for Cohen's cellphone occurred on September 8, 
45110 Cohen subsequently provided Sterling with a revised statement of financial condition, also 
452dated August 1, 2014, which reported assets of $99,420,000, total liabilities of $23,550,000, and a 
453net worth of $75,870,000. 
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4582015—during which Cohen told Sterling Employee-2, in sum and substance, about his cash flow 
459problems and a monthly shortfall of approximately $16,000. In that same email, Sterling 
460Employee-2 commented that despite Cohen's statements, his personal financial information 
461"indicate[d] a strong ability to make up the difference in payments." Cohen, however, according 
462to Sterling Employee-2, pushed the bank for a reduction in Cohen's monthly payments. 
463g. From my review of records maintained by Sterling and my participation in an 
464interview Cohen an&Sterling-Employee-2 spoke 
465again on September 28, 2015, and that during the call Cohen stated, in sum and substance, that the 
466individual to whom Cohen leases the medallions had again reduced monthly payments to Cohen. I 
467know from my review of records maintained by Sterling that between in or about September 2015 
468and November 2015, Sterling raised the possibility—both internally and with Cohen—of Cohen 
469posting his real estate holdings, personal residence, or some other collateral as additional security 
470for the banks.ll According to these records, however, Cohen resisted these requests. From my 
471review of loan documents and records maintained by Sterling, I know that in or about November 
4722015, as a result of Cohen's representation that he was not earning sufficient returns on his 
473medallions to cover monthly interest payments, Sterling and Melrose agreed to amend their loans 
474with Cohen by, among other things, reducing the interest rate Cohen paid to Melrose and extending 
475the loan maturity date to December 8, 2017. 
476h. I know from interviews with Sterling Employee-I and Sterling Employee-2, as well 
477as emails I have reviewed, that in or about October 2016, Cohen told Sterling Employee-I that 
478Cohen had a potential buyer of his taxi medallions, named —who would agree to 
47911 Based on my review of propetty records, I know that on or about October 28, 2015, around 
480the time period when Sterling raised the possibility of Cohen posting his personal residence— 
481Subject Premises-I—as collateral, Cohen transferred Subject Premises-I into a trust. 
48215 
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487assume Cohen's debt with Sterling and Melrose. Based on my review of records maintained by 
488Sterling, as well as the interviews with Sterling Employee-I and Sterling Employee-2 referenced 
489above, I know that by or before October 2016, Cohen had entered into negotiations to sell his sixteen 
490corporate taxi medallion entities to 
491for the balance of the loans, which at the time was $21 I know from my review ofrecords 
492maintained by Sterling, and my participation in an interview with Sterling Employee-2, that as a 
493condition Of the&ansfer-of the medallion-loans—and- beeauseSterlingAvas unfamiliar with 
494—Sterling requested that Cohen make a substantial principal payment on the loan, of 
495approximately one million dollars, prior to the transfer. Cohen rejected this request initially. But 
496on or about January 31, 2017, Cohen told Sterling Employee-I, in sum and substance, that he would 
497make a one million dollar principal reduction payment in order to move forward with the medallion 
498transfer deal with 
499Indeed, in an email sent by Cohen to Sterling Employee-2 on or 
500about February 22, 2017, Cohen confirmed that he "agreed to pay down 1 million from the loan 
501amount." 
502i. Pursuant to the participation agreements between Sterling and Melrose, Sterling 
503was required to secure Melrose's agreement to participate in the transfer of the taxi medallion debt 
504from Cohen to 
505On or about April 17, 2017, Sterling sent a memorandum to 
506Melrose summarizing the terms of the proposed transaction, and noting the requirement that 
507Melrose agree to the terms. On or about May 2, 2017, Sterling Employee-I told 
508that Melrose had agreed to the deal in principle, and that Sterling would be sending the parties a 
509term sheet shortly. 
510j. In order for the banks to conduct diligence and evaluate the proposed transaction 
511fully, they requested financial information from the parties. On or about June 7, 2017, Sterling 
51216 
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517Employee-I emailed Cohen to request an "updated personal financial statement," completed 
518jointly with Cohen's wife, and Cohen's most recent federal income tax return. On or about June 
5198, 2017, Cohen emailed Sterling Employee-I a Sterling personal financial statement form that had 
520been filled out by hand, which referenced a statement of financial condition, dated May 1, 2017 
521(the "May 2017 Financial Statement") that was also attached. The May 2017 Financial Statement 
522included a cover letter from Cohen's accountant, Jeffrey Getzel, stating, in sum and substance, that 
523the information in-the-statement-came-from Cohen-and-thatGetzel had not-confirmed-its-accuracy 
524or completeness. The May 2017 Financial Statement stated that Cohen had total assets of 
525$41,955,000, total liabilities of $39,130,000, and a net worth of $2,825,000. The May 2017 
526Financial Statement indicated that Cohen's assets were comprised of $1,250,000 in cash, 
527$26,155,000 in closely held companies (such as the taxi medallion entities and his real estate 
528holdings), $3,200,000 in real estate investments, and his $11,000,000 personal residence.12 
529k. Based on my review of reports of law enforcement interviews of Sterling 
530Employee-I, I have learned that Sterling Employee-I reviewed the May 2017 Financial Statement 
531with Cohen to, among other things, verify its accuracy, and Sterling Employee-I asked Cohen about 
532specific line items on the financial statement, including the cash amount, value of medallions, and 
533total liabilities. Cohen stated to Sterling Employee-I, in sum and substance, that the May 2017 
534Financial Statement was accurate. 
535l. On or about August 16, 2017, Sterling Employee-I emailed Cohen and 
536attaching a non-binding term sheet memorializing the potential transaction between 
53712 Based on my review of Cohen' s financial statements, I know that the precipitous decline in 
538assets from his 2014 financial statement to his 2017 financial statements can be explained 
539primarily by reported depreciation in the value of Cohen's real estate assets and medallion 
540investments. 
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545Sterling, Melrose, Cohen, and 
546The term sheet included a cover letter addressed 
547to Cohen at Subject Premises-I. The parties negotiated the provisions of the term sheet and, on or 
548about September 5, 2017, Sterling Employee-I sent 
549executed term sheet. According to the term sheet, 
550from Sterling and Melrose, to be secured by the medallions that 
551Cohen. 
552md Cohen a copy of the 
553would b01Tow $20,000,000 
554vas to acquire from 
555m. ASVärtOftheägreement,-accordingtothe term sheets 16265;91-3 in principal (which 
556is what would remain after the $20,000,000 payment on the outstanding loan balance) would be 
557repaid by Cohen and the two banks, with Cohen paying fifty percent and the banks dividing the 
558remaining half of the balance. Based on my review of an internal Sterling credit memorandum, 
559dated October 4, 2017, the parties reached a preliminary agreement that Cohen would pay $632,956 
560of the remaining $1,265,912 principal loan balance, and Sterling and Melrose would absorb 
561$357,167 and $275,789, respectively, in the form ofcharge-offs. According to Sterling Employee- 
5621, Sterling was willing to divide the repayment of the outstanding principal balance—despite its 
563prior insistence that Cohen make a principal pay-down of at least one million dollars—because 
564Cohen represented on a telephone call with Sterling Employee-I , in sum and substance, that he had 
565insufficient liquidity to pay the full outstanding principal balance. As part ofthe agreement, Sterling 
566and Melrose also agreed to relieve Cohen and his wife of the personal guarantees that they made 
567on behalf of the LLCs. Thus, after completing the 
568transaction, Cohen would no longer 
569have had any outstanding obligations to Sterling or Melrose. 
570n. Based on my review of emails sent by Sterling employees, I have learned that 
571because the transaction between the patties was subject to full credit underwriting by Sterling and 
572Melrose (as well as Melrose's regulators at NCUA), in August and September 2017, Sterling 
57318 
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578required and requested additional financial statements and tax returns for Cohen and 
579for its credit underwriting process. In response to Sterling's requests, on or about September 25, 
5802017, Cohen emailed Sterling Employee-2 a copy of his 2016 tax return. The tax ret-um listed 
581Cohen's mailing address as Subject Premises-I. Additionally, on or about October 5, 2017, Cohen 
582re-sent Sterling Employee-2 a copy of his May 2017 Financial Statement. A day later, on October 
5836, 2017, Cohen emailed Sterling Employee-2 a statement of financial condition, dated September 
584"September2017-Financial -Statement"). 
585o. Like the May 2017 Financial Statement, the September 2017 Financial Statement 
586included a cover letter from Jeffrey Getzel, Cohen's accountant, stating, in sum and substance, that 
587the information in the statement came from Cohen, and that Getzel had not confirmed its accuracy 
588or completeness. The September 2017 Financial Statement stated that Cohen had total assets of 
589$33,430,000, total liabilities of $45,630,000, and a negative net worth of $12,200,000.13 Notably, 
590unlike Cohen's May 2017 Financial Statement, the September 2017 Financial Statement 
591represented to Sterling that Cohen had a negative net worth. The September 2017 Financial 
592Statement indicated that Cohen's assets were comprised of $1,250,000 in cash, $17,630,000 in 
593closely held companies (including the taxi medallion entities and his real estate holdings), 14 
594$3,200,000 in real estate investments, and his $11,000,000 personal residence (which, for the first 
59513 Based on my review of Cohen's financial statements, I know that this further decline in 
596assets can be explained primarily by reported depreciation in the value of Cohen's real estate assets 
597and medallion investments. 
59814 Notably, the September 2017 Financial Statement valued each of Cohen's thirty-two New 
599York taxi medallions at approximately $180,187.50, which was considerably less than the 
600"—term sheet. 
601$650,000 valuation ascribed to each medallion in the Cohen- 
60219 
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607time, he indicated was held by a trust).15 The September 2017 Financial Statement included assets 
608and liabilities not held in Cohen's name, such as various entities associated with his taxi medallions 
609and some of his real estate investment entities. 
610p. From my participation in an interview with Sterling Employee-2, and my review of 
611records maintained by Sterling, I have also learned that around the time Cohen provided Sterling 
612with these financial statements—i.e., in or around September 2017—Cohen stopped paying 
613on his taxi-medallionAoans 
6142, Cohen informed Sterling, in sum and substance, that he had insufficient åmds to pay the monthly 
615principal and interest payments on his medallion loans. By in or about December 2017, Sterling 
616and Melrose had not been paid approximately $276,937.92 in monthly principal and interest 
617payments on the medallion loans. Based on Cohen's financial condition as conveyed in the 
618September 2017 Financial Statement, and his delinquency in making payments to Sterling, among 
619other things, the bank's credit underwriting committee determined (and memorialized in a 
620December 2017 memorandum) that the Cohen-' 
621transaction was favorable for the bank 
622— that is, that 
623would be a better borrower than Cohen. 
624q. On or about December 26, 2017, Sterling sent Cohen a demand letter requesting 
625the immediate receipt of past-due loan payments. The demand letter was addressed to Cohen at 
626Subject Premises-I. On December 29, 2017, Sterling sent Cohen a letter stating that he was in 
627default under the loans between Sterling and Cohen's medallion corporations. The notice of 
628default was addressed to Cohen at Subject Premises-I. Cohen did not make an immediate payment 
629on the loans, but instead sent an e-mail to Sterling Employee-I on or about January 24, 2018, 
63015 Based on my review of property records maintained by the City of New York, and my 
631participation in an interview with Getzel, I know that in 2015, Cohen transferred his residence to 
632a trust. 1--1e did not disclose that transaction to Getzel or Sterling until in or about September 2017. 
63320 
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638stating that during the closing of the Cohen• 
639transaction, Cohen would "bring all 
640payments up to date as well as deposit the payoff differential." Cohen also requested by email on 
641January 24, 2018, that at the closing of the Cohen-' 
642transaction, Sterling provide a letter 
643stating that all of Cohen's debts have been satisfied and that Cohen's personal guarantees of the 
644medallion loans had been terminated. 
645r. The Cohen- 
646transaction, however, did not close. On or about January 
647attorney-emailed attorneys-for-Sterling and-stated-thatéfat this-time——- 
648there is no deal with Michael Cohen. Some of the numbers have changed and we are not prepared 
649to go forward." 
650s. Based on my participation in the interview with Sterling Employee-2 and my 
651review of records maintained by Sterling, I know that after the Cohen- 
652deal fell apan, 
653Sterling assigned Cohen's loans to Sterling Employee-3, who specializes in collecting on 
654defaulting loans. From my participation in an interview with Sterling Employee-3, my review of 
655telephone call notes taken by Sterling Employee-3, and my review of telephone records, I know 
656that Sterling Employee-3 spoke several times to Cohen on or about January 30, 2018 about paying 
657down and/or restructuring Cohen's outstanding taxi medallion loans. On the calls, which in total 
658lasted more than an hour, Cohen stated in sum and substance that he did not have more than 
659$1,250,000 to pay toward the medallion loans. On the call, in the course of reviewing the failed 
660Cohen- 
661Cohen and 
662transaction, Sterling Employee-3 questioned Cohen about the price 
663vas to have paid for each medallion, and whether there was a side agreement between 
664Cohen denied that there was any side agreement with 
665t. On or about January 31, 2018, Cohen emailed Sterling Employee-3 and proposed 
666paying $500,000 to bring the loans current and $750,000 to bring the principal balance to 
66721 
6682017.08.02 
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672$20,500,000. Cohen also suggested revised monthly interest payment amounts. The signature 
673block on the email indicated that Cohen's address was the address for Subject Premises-2. On or 
674about January 31, 2018, Sterling Employee-3 responded to Cohen and stated, in sum and 
675substance, that Cohen would need to pay the entirety of the overdue payments and pay down the 
676principal balance of the loan to $20,000,000 (in total, a payment of approximately $1,750,000), 
677and would need to make larger monthly interest payments. 
678u. On or about Cohen-emailedSterling-Emp10yee-3 and-proposed 
679"[playment of $1.250m which ALL can be used to pay down principal, if [Sterling] will waive 
680past due amounts," but stated "I do NOT have more than the $1.250m." (Emphasis in original.) 
681Cohen also stated, in sum and substance, that he had insufficient financial resources to post 
682additional collateral or pre-fund monthly payments. The signature block on the email indicated 
683that Cohen's address was the address for Subject Premises-2. Based on my participation in an 
684interview with Sterling Employee-3, I have learned that since January 30, 2018, Sterling has 
685continued to renegotiate the medallion loans with Cohen based on Cohen's representations about 
686his current financial position. In particular, according to Sterling Employee-3, Cohen and Sterling 
687have an agreement in principal to restructure Cohen's loans based in part of Cohen's agreement to 
688make a principal payment of approximately $750,000, to make a payment of $500,000 to become 
689current on interest payments, and to post $192,000 in cash collateral for his iiiture monthly 
690payments on the loan. Cohen also agreed to pledge an interest he had in a property. Sterling 
691Employee-3 has stated that had Cohen indicated he had more than $1,250,000 available to him, 
692Sterling would have, among other things, negotiated for a larger reduction to the principal amount 
693of the loan. 
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699(ii) Cohen Made Material Misrepresentations About His Finances to Banks 
700Cohen Concealed from Sterling and Melrose Cash Derived from Consulting Work 
70117. As set forth in detail below, despite multiple written and oral representations by 
702Cohen to Sterling (and, by extension, Melrose16) that he had insufflcient funds to pay down the 
703principal balance of the medallion loans, make monthly interest payments, or pay past-due 
704amounts, it appears that between 2016 and the present, Cohen opened and maintained bank 
705accounts -avFirst-Republic-Bank -of-dollars in 
706consulting payments in these accounts, which he did not disclose to Sterling. Cohen set up these 
707accounts and received these funds during the very period in which he made disclosures to Sterling 
708about his personal finances (including his assets and liabilities) and his ability to make payments 
709on the medallion loans. In these disclosures to Sterling—and despite being asked about these bank 
710accounts by his accountant—Cohen misled the bank by claiming he had insufficient liquidity to 
711satisfy his obligations or meet the bank's demands, while withholding information about these 
712ongoing revenue streams and liquid financial assets at First Republic. 
713Specifically, based on my review of documents and bank records produced 
71418. 
715pursuant to a subpoena by First Republic, and my participation in and review of repoffs of 
716interviews with a First Republic sales manager ("First Republic Employee-I ") and a First Republic 
717senior managing director ("First Republic Employee-2"), I have learned, among other things, the 
718following: 
71916 Based on my review of a report of an interview conducted with an employee of Melrose, I 
720have learned that, pursuant to the participation agreement between Sterling and Melrose, Cohen' s 
721financial statements and other records in Sterling's possession were forwarded to Melrose so that 
722Melrose could make a determination as to whether to approve of the Cohen-•— 
723transaction. Based on my review of reports of interviews with Melrose employees, 1 also know 
724ransaction. 
725that Cohen called employees at Melrose regarding the Cohen- 
72623 
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731a. Cohen and his wife have been customers of First Republic since approximately 
732June 2011. Cohen controls several checking and loan accounts at First Republic, some in his own 
733name and others in the names of corporate entities. According to First Republic's know-your- 
734customer records on Cohen, 17 his primary physical address is the address for Subject Premises-I. 
735b. On or about October 26, 2016, in Manhattan, New York, Cohen opened a new 
736checking account at First Republic in the name of Essential Consultants LLC (the "Essential 
737Coiisülfants was the only-authorized-signatoryomthe account—According-to 
738account opening documents, the primary address for Essential Consultants LLC was the address 
739for Subject Premises-I. When Cohen opened the Essential Consultants Account, First Republic 
740Employee-I conducted an in-person interview of Cohen. In response to a series of know-your- 
741customer questions about the purpose of the account—the answers to which First Republic 
742Employee-I entered into a form18 Cohen stated, in sum and substance, that he was opening 
743Essential Consultants as a real estate consulting company to collect fees for investment consulting 
744work, and all of his consulting clients would be domestic individuals based in the United States. 
745Cohen also stated, in sum and substance, that his purpose in setting up the account was to keep the 
746revenue from his consulting business—which he said was not his main source ofincome—separate 
747from his personal finances. As set forth below, there is probable cause to believe that Cohen's 
748statements about the intended purpose of the account and source of fillids for the account were 
749false. Specifically, as described below, the account was not intended to receive—and does not 
75017 Certain financial institutions are required to conduct such procedures pursuant to the Bank 
751Secrecy Act and its implementing regulations. See 31 U.S.C. 5318; 31 C.F.R. 1020.220. 
75218 First Republic Employee-I first filled out the form on the day he interviewed Cohen, October 
75326, 2016. On or about December 19, 2016, at the request of bank compliance personnel, First 
754Republic Employee-I updated the form to add more detail about Cohen's statements. 
75524 
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760appear to have received—money in connection with real estate consulting work; in addition, the 
761account has received substantial payments from foreign sources. 
762c. I know from my review of First Republic bank records that were scheduled by an 
763FBI forensic accountant that after Cohen opened the Essential Consultants Account, Cohen 
764received payments into that account from foreign businesses and entities that do not reflect the 
765stated client profile for the residential and commercial real-estate consulting services. Specifically, 
766fröm-my-reNiew-of 
767following: 
768i. Beginning on or about January 31, 2017, Cohen began receiving monthly 
769payments of $83,333 into the Essential Consultants Account from an entity called Columbus Nova 
770LLC. According to public sources, Columbus Nova is an investment management firm controlled 
771by Renova Group, an industrial holding company based in Zurich, Switzerland that is controlled 
772by Russian national Viktor Vekselberg. From January 2017 to August 2017, the Essential 
773Consultants Account received seven payments totaling $583,332.98 from Columbus Nova LLC. 
774ii. Beginning on or about April 5, 2017, the Essential Consultants Account 
775began receiving payments from Novartis Investments, SARL, which I believe to be the in-house 
776financial subsidiary ofthe Swiss pharmaceutical company Novartis International AG ("Novartis"). 
777Between April 2017 and February 2018, the Essential Consultants Account received eleven wire 
778payments from a Swiss bank account held in the name of Novartis, each in the amount of $99,980, 
779for a total of 
780iii. Beginning in or about April 2017, the Essential Consultants Account started 
781receiving wire payments from a bank account associated with the telecommunications company 
782AT&T Inc. ("AT&T"). Specifically, on or about April 14, 2017, AT&T sent $100,000 to the 
78325 
7842017.08.02 
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788Essential Consultants Account and, from in or about June 2017 to in or about January 2018, the 
789Essential Consultants Account received ten $50,000 payments from AT&T. In total, AT&T sent 
790$600,000 to the Essential Consultants Account. 
791iv. On or about May 10, 2017, June 9, 2017, July 10, 2017, and November 27, 
7922017, the Essential Consultants Account received four deposits in the amount $150,000 (totaling 
793$600,000) from a bank account in South Korea. The account holder from which the money was 
794Sent iSXOiéiAerospace company that 
795produces and sells fixed-wing aircraft, helicopter aircraft, and satellites to the United States 
796Department of Defense, among other customers. 
797v. On or about May 22, 2017, the Essential Consultants Account received a 
798$150,000 deposit from an account at Kazkommertsbank, a Kazakhstani bank. The listed account 
799holder at Kazkommertsbank was a second Kazakhstani bank named BTA Bank, AO. A message 
800accompanying the wire payment indicated that the payment was a "monthly consulting fee as per 
801Inv BTA-IOI DD May 10, 2017 consulting agreement W/N DD 08 05 2017 CNTR W/NDD 
80208/05/2017." 
803vi. In total, from on or about January 31, 2017 toon or about February 1, 2018, 
804the Essential Consultants Account received approximately $3,033,112.98 in transfers and checks 
805from the aforementioned entities. As of on or about January 10, 2018, the balance in the Essential 
806Consultants Account was $1,369,474.23. Cohen's withdrawals from the Essential Consultants 
807account reveal that it was used for largely personal purposes, including to pay, among other things, 
808American Express bills and fees from "the Core Club," a private social club in New York. 
809d. On or about April 4, 2017, Cohen opened another new checking account at First 
810Republic, this one in the name ofMichael D. Cohen & Associates, P.C. (the ' 'MDC&A Account"). 
81126 
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816Cohen was the only authorized signatory on the account. According to account opening 
817documents, the primary' address for IVIDC&A Account was the address for Subject Premises-I. 
818Among other things, the MDC&A Account received ten wire transfers and one check from an 
819account in the name of Squire Patton Boggs, a law firm. As noted above, Subject Premises-2 is 
820located inside the New York office of Squire Patton Boggs. In total, from on or about April 5, 
8212017, to on or about January 2, 2018, the MDC&A Account received $426,097.70 in deposits, and 
822tfre balance below„Cohen— 
823never disclosed any of the balance in the Essential Consultants or MDC&A accounts to Sterling 
824during the negotiations with respect to the 
825transaction or the subsequent loan 
826refinancing negotiations, including in his May 2017 Financial Statement and September 2017 
827Financial Statement. 
82819. Based on my review of emails that were seized pursuant to the Cohen Email 
829Warrants, and my review of repotts of interviews with employees of AT&T and Novartis, it 
830appears that the aforementioned payments to the Essential Consultants Account and MDC&A 
831Account were for political consulting work, including consulting for international clients on issues 
832pending before the Trump administration. Specifically, from my review ofemails from the Cohen 
833Gmail Account, the Cohen MDCPC Account, and public sources, I have learned the following: 
834a. On or about April 28, 2017, Cohen sent an email to an individual whom I believe 
835is affiliated with KAT. In the email, Cohen attached a "Consulting Agreement" between KAI and 
836Essential Consultants dated as of about May 1, 2017. The agreement indicates that Essential 
837Consultants had the address of Subject Premises-2. The document indicates that Essential 
838Consultants would render "consulting and advisory services, as requested" by KAI, and that KAI 
839would pay Essential Consultants "a consulting fee of One Million Two Hundred Thousand 
84027 
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845($1,200,000.00) US Dollars," disbursed through eight $150,000 installments between May 2017 
846and December 2017. I have also reviewed invoices in amounts of $150,000 that Cohen emailed 
847to an individual whom I believe is affiliated with KAI. At the top of the invoices the address listed 
848for Essential Consultants is the address for Subject Premises-2. 
849b. On or about May 8, 2017, Cohen sent an email to an individual whom I believe is 
850affiliated with BTA Bank. The signature block on Cohen's email listed "Essential Consultants 
851LLC" and "MiChaeVD. address for-Subject-Premises- 
8522. In the email, Cohen attached a document purporting to be a "Consulting Agreement" between 
853BTA Bank and Essential Consultants dated as ofabout May 8, 2017. The agreement indicates that 
854Essential Consultants had the address of Subject Premises-2. The document indicates that 
855Essential Consultants would render "consulting and advisory services" to BTA Bank, and that 
856BTA Bank would pay Essential Consultants "a consulting fee of One Million Eight Hundred 
857Thousand ($1,800,000.00) US Dollars," disbursed through monthly payments of $150,000. On or 
858about May 10, 2017, Cohen sent an email to an employee ofBTA Bank, and attached to the email 
859an invoice to BTA Bank in the name of Essential Consultants, with the address of Subject Premises- 
8602. The invoice contemplated a $150,000 payment to Essential Consultants for a "monthly 
861consulting fee." 
862c. On or about January 23, 2017, Cohen appears to have entered into a consulting 
863agreement with AT&T, which contemplates that Essential Consultants "shall render consulting and 
864advisory services to [AT&T]" and that AT&T would "advise [Essential Consultants] ofthose issues 
865and matters with respect to which AT&T Services desires [Essential Consultants]'s assistance and 
866advice." The agreement indicates that Essential Consultants had the address of Subject Premises- 
867I. The contract calls for AT&T "to pay the Consultant for his services ... a consulting fee of Fifty 
86828 
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873Thousand ($50,000) Dollars ... per month." Based on my review of reports of interviews with 
874AT&T employees, I have learned that AT&T retained Cohen to consult on political issues, 
875including net neutrality, the merger between AT&T and Time Warner, and tax reform. 
876d. On or about March 1, 2017, Cohen appears to have entered into a contract between 
877Novartis and Essential Consultants, which provides that Essential Consultants will firovide 
878consulting and advisory services to Novartis on matters that relate to the repeal and replacement of 
879the [Essentia 
880Consultants] and Novartis." The contract provides for a "consulting fee of One Million Two 
881Hundred Thousand ($1,200,000) Ijs dollars," to be paid to Essential Consultants in equal monthly 
882installments over the course ofa year. Based on my review of reports of interviews with Novartis 
883employees, I have learned that Novartis retained Cohen to provide political consulting services and 
884to gain access to relevant policymakers in the Trump Administration. 
885e. In or about February 2017, Cohen began negotiating the terms of a "strategic 
886alliance" with Squire Patton Boggs. On or about March 4, 2017, Squire Patton Boggs emailed 
887Cohen a "strategic alliance agreement." Under the terms of the agreement, Cohen agreed to 
888generate business for the law firm, and Squire Patton Boggs agreed to pay to Cohen "an annual 
889strategic alliance fee of $500,000, payable in twelve (12) equal monthly installments." Squire 
890Patton Boggs also agreed to provide Cohen with "dedicated and segregated office space in [Squire 
891Patton Boggs's] New York and Washington D.C. offices, which office space shall be physically 
892separate from [Squire Patton Boggs's] offices and have locked doors and its own locked file 
893cabinets." On or about April 3, 2017, Squire Patton Boggs announced on its website that is had 
894formed a "strategic alliance" with Michael D. Cohen & Associates and would "jointly represent 
895clients." 
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90120. Despite the significant amount of money that Cohen received into the Essential 
902Consultants Account and the MDC&A Account, and the cash balance in both accounts, Cohen did 
903not disclose that information to Sterling or Melrose. Specifically, based on my review ofdocuments 
904provided by Getzel (as noted above, Cohen's accountant at the time), my participation in an 
905interview with Getzel, and my review of notes and 
906have learned the following: 
9071 
908-I 
909meeting, Cohen told Getzel, in sum and substance, that he had set up a law practice called Michael 
910D. Cohen & Associates P.C., and a consulting company called Essential Consultants LLC. Cohen 
911told Getzel, in sum and substance, that he expected to earn $75,000 per month in connection with 
912his law practice, and that he expected gross revenues for the consulting business to be between five 
913and six million dollars annually. 
914b. In or about October 2017, if not earlier, Getzel was preparing a personal financial 
915statement for Cohen. On or about October 6, 2017, Getzel sent an email to Cohen in which Getzel 
916wrote that "[a]ttached is a draft of the new PFS as of September 30, 2017" and attached a draft of 
917the September 2017 Financial Statement. The draft statement reflected that as of September 30, 
9182017, Cohen had only $1,250,000 in cash, total assets of apptoximately $33,430,000 (comprised of 
919taxi medallion interests, real estate interests, and his personal residence and propeny), and liabilities 
920ofapproximately $45,630,000, leaving him purportedly over $12 million in debt. In the same email, 
921Getzel questioned Cohen, in sum and substance, about the fact that the financial statement did not 
922list any value associated with either the Essential Consultants Account or the MDC&A Account: 
923"[w]e did not add any value for you[r] two operating entities — Michael D. Cohen & Associates 
92430 
9252017.08.02 
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929POC [sic] and Essential Consultants LLC. Please advise whether or not these should be disclosed 
930and what value." 
931c. On or about October 6, 2017, Cohen called Getzel by telephone—which is reflected 
932on toll records for Cohen's cellphone—and told Getzel, in sum and substance, not to include 
933Essential Consultants or MDC&A in the September 2017 Financial Statement because they had no 
934value. On or about October 6, 2017, following the call with Getzel, Cohen, using the Cohen 
935email Witfrthe-answer "[l]ooks good to me&Cohennever-directed 
936Getzel to make any changes to his cash position as listed in the September 2017 Financial 
937Statement. In a letter dated October 6, 2017, addressed to Getzel, Cohen stated, "I have reviewed 
938the attached statement of financial condition and find it to be correct and consistent with the 
939representations that I made to your finn. The attached is an accurate reflection of my assets, 
940liabilities and net worth (deficit) as of September 30, 2017." Attached to that letter was the 
941September 2017 Financial Statement, which, as noted above, was then transmitted to Sterling in 
942connection with the proposed taxi medallion transaction between Sterling, Cohen, and 
94321. Based on my review of a report of an interview with Sterling Employee-I, I have 
944leamed that Cohen did not disclose his income stream from Essential Consultants to Sterling 
945Employee-I or, to his knowledge, anyone else at Sterling. According to Sterling Employee-I, 
946knowledge of such an income stream would have affected Sterling's demands during the 
947negotiations, particularly with respect to the amount of a principal paydown of Cohen's debt. 
948Cohen Understated His Available Cash 
94922. In addition to withholding the existence of his Essential Consultants income from 
950Sterling and Melrose, it appears that Cohen also substantially understated his available cash and 
951cash equivalents in his financial disclosures. Specifically, I know from my review ofthe September 
95231 
9532017.08.02 
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9572017 Financial Statement that Cohen provided to Sterling that Cohen represented that he had 
958$1,250,000 in cash as of September 30, 2017. I also know that on or about January 30, 2018, in a 
959telephone call with Sterling Employee-3, and on February 1, 2018, in an email to Sterling 
960Employee-3, Cohen represented that he did not have more than $1,250,000 in cash. But, from my 
961review of a summary ofbank records that were scheduled by forensic accountants, I have learned 
962that Cohen had approximately $5,000,000 in cash and cash equivalents as of September 30, 2017. 
963had-approximately-S6,000,000-in-cash-and- cash 
964equivalents. Specifically, from my review ofthe account schedule and bankrecords, I have learned 
965the following: 
966a. Cohen has three checking and/or savings accounts at Capital One Bank, one of 
967which is in his wife's name. As of September 30, 2017, Cohen had $1,105,680.35 in his savings 
968account, and $1,262,982.29 in total in the three accounts at Capital One Bank. As of February 1, 
9692018, Cohen had a total of $1,3 89,245.78 in these accounts. 
970b. Cohen has three accounts at Morgan Stanley in his name. As of September 30, 
9712017, the combined total in cash and cash equivalents in those three accounts was $1,270,600.41. 
972As of February 1, 2018, Cohen had $1,284.996.13 in these accounts. 
973c. As of September 30, 2017, Cohen had $260,689.18 in an accountatSignatureBank. 
974As of February 1, 2018, Cohen had $261,517.55 in this account. 
975d. In addition to the Essential Consultants Account and MDC&A Account at First 
976Republic, Cohen also had twojoint checking accounts with Laura Cohen at First Republic. In total, 
977as of September 30, 2017, Cohen had at least $1,876,209.27 in total in his four accounts at First 
978Republic. As of February 1, 2018, Cohen had $3,332,992.95 in these accounts. 
97932 
9802017.08.02 
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984e. Cohen has an account at Bethpage Credit Union with $25,931.39 in it as of 
985September 3(), 2017. 
986f. As of September 30, 2017, Cohen had $17,542.54 in accounts at Sterling. 
987g. Cohen has two accounts at TD Bank—one in his name and one held jointly with his 
988wife. Cohen also has a safety deposit box at TD Bank—Subject Premises-3. The safety deposit 
989box was opened on December 13, 2017 in the names of Michael and Laura Cohen. 
990of had in his accounts 
991at Capital One Bank, City National Bank, Signature Bank, Sterling Bank, Bethpage Credit Union, 
992First Republic, and Morgan Stanley. As of February 1, 2018, Cohen had $6,268,732.59 in his 
993accounts at Capital One Bank, City National Bank, Signature Bank, First Republic, and Morgan 
994Stanley. 19 
99523. Accordingly, based on the foregoing, it appears that Cohen's written and oral 
996representations to Sterling and Melrose that he did not have more than $1 were false, and 
997that Cohen withheld information regarding approximately $5 million in funds from Sterling and 
998Melrose in order to secure favorable terms in his renegotiation of his medallion loan. Based on 
999my participation in an interview with Sterling Employee-2, and my review ofreports of interviews 
1000with Sterling Employee-I and two Melrose employees, it is my understanding that that Sterling 
1001and Melrose would view Cohen's understating of his assets as material to its decision whether to 
1002renegotiate Cohen's medallion loans and on what terms, or to its decision whether approve of the 
1003transfer of those loans to 
100419 Based on my review of the account schedules described above, I know that, as of the date of this 
1005affidavit, the account balances for TD Bank have not yet been included in the schedule for either 
1006date and the account balances for Sterling National Bank and Bethpage Credit Union have not yet 
1007been included in the schedule for February 1, 2018. Thus, to the extent that these accounts have 
1008positive balances, Cohen's total balances in fact were even higher on these dates. 
100933 
10102017.08.02 
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1014Cohen Has Unreported Interest Income 
1015It appears that Cohen also hid from Sterling interest income that he was receiving in 
1016connection with a six million dollar loan he made to another individual. Specifically, I know from 
1017my review of the May 2017 Financial Statement and September 2017 Financial Statement that 
1018Cohen provided to Sterling that Cohen did not disclose that he had made a note receivable in the 
1019amount of approximately $6 million, or that he was earning approximately $60,000 per month in 
1020*merest-income-in-connection-with that 
1021that were reviewed by another law enforcement agent, my review of propelly records and 
1022documents obtained pursuant to the Cohen Email Warrants, and my participation in an interview 
1023with Getzel, I have learned the following: 
1024a. Based on my review of property records, I have learned that on or about March 12, 
1025upproximately 
10262012, Cohen agreed to lend 
1027$2,000,000.20 It appears that the promissory note was unsecured by any real property. On or about 
1028amended the promissory note, and restructured the loan to 
1029April 28, 2014, Cohen and 
1030increase the principal amount to approximately $5,000,000. Under the terms of the amended 
1031promissory note, the loan was secured by— artmentin Sunny Isles Beach, Florida. On 
1032stated the promissory note to increase the principal 
1033or about April 8, 2015, Cohen and 
1034amount to $6,000,000.21 
1035b. Based on my review ofa copy of the restated note, which was obtained pursuant to 
1036the Cohen Email Warrants, I have learned that under the terms of the amended and restated 
103720 | learned from Getzel that 
103821 The note states that the loan is to wife, 
1039lerein. 
1040jointly and severally. For ease of reference, I refer simply to " 
104134 
10422017.08.02 
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1046promissory note, Cohen's loan to —s an interest-only loan, and that the principal balance 
1047of the loan bears interest at an annual rate of 12.25 percent. I also know that the amended and 
1048restated promissory note includes a schedule of payments that require 
1049to pay Cohen 
1050approximately $61,250 permonth beginning in April 2015 and ending in April 2019. The note also 
1051—epay the principal balance of on April 28, 2019. 
1052requires thal 
1053c. Based on my review of bank records, I have learned that, consistent with the terms 
1054of—the--amended—and—restated—promissory -notew- 
1055approximately $61,250 since April 2015. Specifically, based on my review of records maintained 
1056by Capital One Bank, I have learned that from April 2015 to October 2015, Cohen received checks 
1057totaling $61,250 per month, which he 
1058from an entity called 
1059deposited into his personal bank account at Capital One Bank.22 It appears from my review ofbank 
1060the owner of 
1061records and public sources that 
1062From my review ofrecords maintained by Capital One Bank, I have also leamed that since October 
10632015, Cohen has received checks from an entity called 
1064totaling 
1065$61,250 per month, which he deposited into his personal bank account at Capital One Bank. It 
1066appears from my review of bank records and public sources that 
1067s also the owner of 
1068it appears that Cohen receives approximately $735,000 per year 
1069in interest payments from 
1070d. Based on my review of Cohen's May 2017 and September 2017 Financial 
1071Statements, my review of his 2015 and 2016 tax returns obtained via subpoena and from the Cohen 
1072Email Warrants, and my participation in an interview with Getzel, I have learned that Cohen did 
107322 In April 2015, Cohen received a pro-rated payment. For all months thereafter, the total payment 
1074equaled $61,250, but —)ften made the payment in multiple checks. 
107535 
10762017.08.02 
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1080not disclose this interest income he was receiving from 
1081to Sterling or Melrose, or list it 
1082on his tax returns. I have also learned that while this interest income is taxable, Cohen did not tell 
1083Getzel—his accountant—about the income, and Getzel only learned about the income because he 
1084—taxes in 2017.23 
1085began doing 
108625. Accordingly, based on the foregoing, it appears that Cohen's representations to 
1087Sterling and Melrose that he did not have more than $1,250,000 were false, and that Cohen 
1088in-Ordevto 
1089withheld information re from 
1090secure favorable terms in his renegotiation of his medallion loan. 
1091Cohen Had a Side Agreement With 
109226. As set forth in detail below, during the course of Cohen's negotiations to sell his 
1093interest in taxi medallions and the associated debt to 
1094Cohen not only 
1095misrepresented his financial position to Sterling, but also failed to disclose a side agreement he 
1096= greed to pay an above-market price 
1097it aPpears that 
1098had negotiated with 
1099for Cohen's taxi cab medallions, and in exchange, Cohen agreed to pay = 
1100tpproximately 
1101$3.8 million in cash. Specifically, from my review ofdocuments produced pursuant to a subpoena 
1102by Sterling, and my participation in interviews with Sterling Employee-I, Sterling Employee-2, 
1103and Sterling Employee-3, I have learned, among other things, the following: 
1104a. On or about September 5, 2017, an executed term sheet was circulated by Sterling 
1105Employee-I to Cohen and 
1106The term sheet listed Cohen's address as the address for 
1107borrow 
1108Subject Premises-I. According to the tenn sheet, 
1109from Sterling and Melrose, to be secured by the medallions that 
1110was to acquire from 
111123 Accordingly, this interest income—which should have been reported as such on Cohen's tax 
1112returns—is included hetein in calculations of Cohen' s true cash position. 
111336 
11142017.08.02 
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1118Cohen. At a price of $20 million for thirty-two taxi medallions, the proposed transaction valued 
1119each medallion as worth $625,000. The term sheet also contemplated a $1,265,913 pay-down of 
1120the principal balance of the loan. The term sheet made no mention ofa $3.8 million payment from 
1121Cohen to or any other form of payment or financial transaction between the panies. 
1122b. Additionally, an internal Sterling credit memorandum, dated October 4, 2017, 
1123describing the terms ofthe Cohen- 
1124transaction and the new loan to —did 
1125not mention any paymentS from Cohen-to—including-aa$3.8-million payment.= The 
1126memorandum also noted that the "loan amount of $20MM indicates a $625M purchase price per 
1127medallion" but "it is recognized that this is not in line with current market values." Indeed, 
1128according to an internal Sterling memorandum dated February 5, 2018, in the month of January 
11292018, taxi medallions sold for amounts ranging from $120,000 to $372,000. According to Sterling 
1130Employee-I and Sterling Employee-2, they were never told that 
1131lgreed to a purchase 
1132price of $625,()0() in exchange for a lump sum payment from Cohen, or that Cohen would make 
1133any payment to 
1134c. On or about January 30, 2018, Sterling Employee-3 asked Cohen whether Cohen 
1135had a side agreement with 
1136a sum of money for entering into the 
1137medallion transaction. Sterling Employee-3 asked Cohen about such an arrangement because, 
1138according to Sterling Employee-3, the price that 
1139was paying for each medallion 
1140appeared to be well above the market price. Cohen stated, in sum and substance, that he had no 
1141side agreement—and never had a side agreement—with 
114227. While Cohen and 
1143did not disclose any payment from Cohen to 
1144in communications with Sterling, it appears that such a payment was contemplated. 
1145Indeed, based on my review of records maintained by Getzel, and my participation in an interview 
114637 
11472017.08.02 
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1151with Getzel, I have learned the following, in substance and in part, regarding the proposed side 
1152payment from Cohen to— 
1153a. On or about September 19, 2017, Getzel prepared a memorandum for Cohen 
1154entitled, "Sale of NYC Medallion Entities and Debt Assumption" (the "Getzel Memorandum"). 
1155The Getzel Memorandum summarized the proposed transaction between Cohen and 
1156in part, as follows: "Michael and Laura Cohen will transfer ownership of their 13 NYC medallion 
1157entities to a Buyer who willÄüifiöthéir bankindebtedness;-upon the 
1158debt portfolio of the 13 entities by $500,000 and a cash payment to the Buyer of 
1159b. According to Getzel, Cohen told him the parameters of the deal, including the 
1160payment of $3,800,000 to 
1161to pay 
1162but Getzel did not know where Cohen was going to obtain 
1163As noted above, Cohen had more than $5,000,000 in cash and 
1164cash equivalents as of September 2017, but had only disclosed in his September 2017 Financial 
1165Statement that he had $1.25 million in cash. 
116628. Based on my review of records maintained by Sterling (as well as Melrose, the bank 
1167with the participating interest in the loans) and reports of interviews of representatives of Sterling 
1168(and Melrose), I have seen no evidence that Sterling, Melrose, or any other financial institution 
1169involved in the potential deal with Cohen and 
1170side payment from Cohen tc 
1171was aware of the planned $3.8 million 
1172The Illegal Campaign Contribution Scheme 
117329. The USAO and FBI are also investigating a criminal violation of campaign finance 
1174laws by Michael Cohen. As set forth below, there is probable cause to believe that Cohen made 
117524 The reference to thirteen medallions appears to be an error by Getzel. Cohen and his wife 
1176together owned sixteen corporations, which in turn owned 32 taxi medallions. 
117738 
11782017.08.02 
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1182an excessive in-kind contribution to the presidential election campaign of then-candidate Donald 
1183Trump in the form of a $130,000 payment to Stephanie Clifford, an individual who was rumored 
1184to have had an extramarital affair with Trump, in exchange for her agreement not to disclose that 
1185alleged affair. As set forth below, there is probable cause to believe that this payment was intended 
1186to keep Clifford from making public statements about the rumored affair on the eve of the 2016 
1187presidential election, and thus constitutes a campaign contribution in excess of the applicable limit. 
118830. From my review Of biiblie-sources, I-have-learned-the-following: 
1189a. In or around October 2011, there were rumors published on the gossip websites 
1190TheDirIy.com that Trump had had an extramarital affair with Clifford, an adult film actress whose 
1191screen name is Stormy Daniels, in or around July 2006. In or about October 2011, Life & Style 
1192Magazine, a tabloid sold in supermarkets, also published an article, based on the report in 
1193TheDirty.com, alleging an affair had occurred between Trump and Clifford. Both Trump and 
1194Clifford, through their representatives, issued denials in response to the articles. 
1195b. Specifically, on or about October 11, 2011, Keith Davidson, who identified himself 
1196as Clifford's attorney, sent a cease and desist letter to TheDirty.com, demanding that the article 
1197regarding Trump and Clifford be removed from the website. Additionally, on or about October 
119812, 2011, Cohen, who was then Executive Vice-President and Special Counsel to the point 
1199Organization, stated to E! News that "[t]he totally untrue and ridiculous story ... emanated from 
1200a sleazy and disgusting website.... The Trump Organization and Donald J. Trump will be bringing 
1201a lawsuit ... [and] Mr. Trump and the Trump Organization would like to thank and commend 
1202Stormy Daniels and her attorneys for their honesty and swift actions." 
120331. On or about June 16, 2015, Trump formally launched his 2016 presidential 
1204campaign. On or about May 4, 2016, Tnlmp became the presumptive Republican Party nominee 
120539 
12062017.08.02 
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1210for president, and on July 19, 2016, Trump officially became the nominee. Based on my review 
1211of public sources, I have learned that while it does not appear that Cohen had an official title as 
1212part of the Trump campaign, on multiple occasions Cohen made public statements on behalf of 
1213Trump or his campaign. For instance, on or about August 18, 2016, Cohen appeared on CNN to 
1214defend Trump's polling numbers. 
121532. On or about October 7, 2016, The Washington Post published online a video and 
1216accompanying audio in whiCIiTi'üinp article-describe&as "vulgar 
1217terms" in a 2005 conversation with Billy Bush, who was then the host of Access Hollywood. The 
1218following day, on October 8, 2016, Trump appeared in a video in which he stated, among other 
1219things, "I've said and done things I regret and words released today on this more than a decade old 
1220video are one of them. Anyone who knows me knows these words don't reflect who I am. I said 
1221it. I was wrong and I apologize." Based on my review of public sources, I also know that 
1222representatives of the Trump Campaign stated, in sum and substance, that the Access Hollywood 
1223comment was an old and isolated incident. 
122433. Based on my review of public sources, including an article published in Slate 
1225magazine by a reporter who interviewed Clifford, I have leamed that around this same time, in or 
1226about October 2016, Clifford was in discussions with ABC's Good Morning America show and 
1227Slate magazine, among other media sources, to provide these media outlets with her statement 
1228about her alleged relationship with Trump. According to the article in Slate, which the author 
1229based on conversations with Clifford over the telephone and by text message, Clifford wanted to 
1230be paid for her story or be paid by Trump not to disclose her accusation. As Cohen summarized 
1231in a 2018 email obtained pursuant to the Cohen Email Warrants: "In October 2016, I was contacted 
123240 
12332017.08.02 
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1237by counsel for Ms. Clifford stating that news outlets, including ABC News, were pursuing the 2011 
1238story of an alleged affair between Mr. Trump and Ms. Clifford." 
123934. From my review of telephone toll records25 and information produced pursuant to 
1240the iCloud Warrant and Cohen Email Warrants, I have learned that in the days following the Access 
1241Hollywood video, Cohen exchanged a series of calls, text messages, and emails with Keith 
1242Davidson, who was then Clifford' s attorney, David Pecker and Dylan Howard of American Media, 
1243Hope Hicks;-who-was-them 
1244press secretary for Trump's presidential campaign. Based on the timing of these calls, and the 
1245content of the text messages and emails, I believe that at least some of these communications 
1246concerned the need to prevent Clifford from going public, particularly in the wake of the Access 
1247Hollywood story. In particular, I have learned the following: 
1248a. On October 8, 2016, at approximately 7:20 p.m., Cohen received a call from Hicks. 
1249Sixteen seconds into the call, Trump joined the call, and the call continued for over four minutes.27 
1250Based on the toll records that the USAO has obtained to date, I believe that this was the first call 
1251My attribution of certain telephone numbers to certain individuals as described in this 
125225 
1253affidavit is based on my review of the vCard (virtual contact file) and text messages obtained from 
1254Cohen's telephone pursuant to the iCloud Warrant. 
125526 Pecker is President of AMI and, according to his own statements in public reports, a personal 
1256friend of Trump. Howard is the chief content offcer of AMI, who according to public records 
1257reports directly to Pecker. 
125827 | believe that Trump joined the call between Cohen and Hicks based on my review of toll 
1259records. Specifically, I know that a call was initiated between Cohen's telephone number and 
1260Trump's telephone number at the same time the records indicate that Cohen was talking to Hicks. 
1261After the Cohen-Trump call was initiated, it lasted the same period of time as the Cohen-Hicks 
1262call. Additionally, the toll records indicate a "-1" and then Trump's telephone number, which, 
1263based on my training and experience, means that the call was either transferred to Trump, or that 
1264Trump was added to the call as a conference or three-way call participant. In addition, based on 
1265my conversations with an FBI agent who has interviewed Hicks, I have learned that Hicks stated, 
1266in substance, that to the best of her recollection, she did not learn about the allegations made by 
1267Clifford until early November 2016. Hicks was not specifically asked about this three-way call. 
126841 
12692017.08.02 
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1273Cohen had received or made to Hicks in at least multiple weeks, and that Cohen and Trump spoke 
1274about once a month prior to this date — specifically, prior to this call on October 8, 2016, Cohen 
1275and Trump had spoken once in May, once in June, once in July, zero times in August, and twice 
1276in September. 
1277b. Approximately ten minutes after the call ended, Hicks and Cohen spoke again for 
1278about two minutes. 
1279c. At 
1280David Pecker (as noted above, the President of American Media Inc., or AMI) and they connected 
1281for thirty seconds. Approximately four minutes later, Cohen called Pecker again and they spoke 
1282for more than a minute. Three minutes after ending his call with Pecker, Cohen received a call 
1283from Dylan Howard (as noted above, the Chief Content Officer of AMI), and they spoke for 
1284approximately a minute. According to toll records, it does not appear that Cohen and Howard 
1285spoke regularly prior to October 8, 2016, as it had been over a month since they had called cach 
1286other. 
1287d. At 7:56 p.m., approximately eightminutes after his call with Howard ended, Cohen 
1288called Hicks and they connected for two minutes. At approximately the same time this call ended, 
1289Cohen received a call from Pecker, and they spoke for about two minutes. At 8:03 p.m., about 
1290three minutes after ending his call with Pecker, Cohen called Trump, and they spoke for nearly 
1291eight minutes. 
1292e. At 8:39 p.m. and 8:57 p.m., Cohen received calls from Howard and spoke to him 
1293for about four and six minutes, respectively. At 9:13 p.m., about ten minutes after Cohen and 
1294Howard hung up from the second of these calls, Howard sent Cohen a text message that said: 
1295"Keith will do it. Let's reconvene tomorrow." Based on my involvement in this investigation, I 
129642 
12972017.08.02 
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1301believe that when Howard wrote "Keith," he was referring to Keith Davidson, the attorney for 
1302Stephanie Clifford. At 3:31 a.m., now on October 9, 2016, Cohen sent Howard a text message in 
1303response that said: "Thank you." Eight minutes later, Cohen sent Howard a text message that said: 
1304"Resolution Consultants LLC. is the name of the entity I formed a week ago. Whenever you wake, 
1305please call my cell." 
1306f. The following day, on October 10, 2016, at 10:58 a.m., Howard sent a text message 
1307to Cohen and Davidson, whiCh¯Stäted: "K-eith/Michael:-connecting-you-botlvin-regards-to-that_ 
1308business opportunity. Spoke to the client this AM and they're confirmed to proceed with the 
1309opportunity. Thanks. Dylan. Over to you two." At 12:25 p.m., Davidson sent Cohen a text message 
1310that stated: 'Wlichael — if we are ever going to close this deal — In my opinion, it needs to be today. 
1311Keith." Davidson and Cohen then spoke by phone for about three minutes. Based on my 
1312participation in this investigation, I believe that when Howard wrote that the "client" was 
1313"confirmed to proceed with the opportunity," he was referring to Clifford's agreement in principle 
1314to accept money from Cohen in exchange for her agreement not to discuss any prior affair with 
131528 
1316then-candidate Trump. 
1317g. Based on my review of records obtained pursuant to the Cohen Email Warrants, I 
1318know that on or about October 10, 2016, Clifford and Davidson appear to have signed a "side letter 
1319agreement" that stated it was an exhibit to a "confidential settlement agreement and mutual 
1320release" between "Peggy Peterson" and "David Dennison." The purpose of the document, 
132128 As set forth below, AMI was also involved in a payment to model Karen McDougal. 
1322However, because these communications were in close temporal proximity to the events involving 
1323the negotiation of a payment to Clifford, the execution of the agreement with Clifford, and the 
1324payment of money to Clifford, I believe that these communications were related to Clifford. 
1325Additionally, based on my review of public statements by McDougal, I have learned that she 
1326negotiated an agreement with AMI several months prior to these communications between Cohen 
1327and Pecker, Howard, and Davidson. 
132843 
13292017.08.02 
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1333according to the agreement, was to define the "true name and identity" of persons named by 
1334pseudonym in "confidential settlement agreement and mutual release." The side letter agreement 
1335specifies the identity of "Peggy Peterson" to be Clifford, but the space for "Dennison's" identity 
1336is blank. The agreement also includes a signature page for "Peterson," "Dennison," and their 
1337attorneys. The signature page is signed by "Peterson" and his attorney, Davidson, but the 
1338document is unsigned by "Dennison" and his attorney. Based on my involvement in this 
1339investigaii6hJFeliéVe¯thå€DavTdson 
1340order to facilitate the closing of a deal between Davidson's client and Cohen or his client on 
1341October 10, 2016. 
1342It appears that on October 13, 2016, and the days that followed, Cohen took steps 
134335. 
1344to complete a transaction with Davidson, including attempting to open an account from which 
1345Cohen could transfer funds to Davidson. Specifically, from my review of toll records, information 
1346obtained pursuant to the iCloud Warrant and Cohen Email Warrants, records maintained by First 
1347Republic, as well as my participation in interviews with First Republic employees, I have learned 
1348the following: 
1349a. On themorning ofOctober 13, 2016, at 8:54 a.m., Cohen sent Pecker atextmessage 
1350that stated: "I need to talk to you." At 9:06 a.m., Pecker sent a text message to Cohen that stated, 
1351"I called please call me back." The tolls between Cohen and Pecker do not show a telephone call 
1352between 8:54 a.m. and 9:06 a.m. However, based on my review of text messages, I have learned 
1353that Cohen and Pecker communicate with each other over Signal, which is an encrypted 
1354communications cellphone application that allows users to send encrypted text messages and make 
1355encrypted calls. 
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1361b. At 9:23 a.m., Cohen sent an email that stated "call me" to First Republic Employee- 
13622. The email attached documents from the Secretary of State of Delaware indicating that Cohen 
1363had formed a limited liability company called "Resolution Consultants LLC" on September 30, 
13642016. As noted above, "Resolution Consultants" is the name of the entity that Cohen had told 
1365Howard he had formed recently after Howard said Davidson would "do it." At 10:44 a.m., Cohen 
1366called First Republic Employee-2 and told him, in sum and substance, that he needed an account 
1367in the name of "Resoliiti6iiCöi1sultåiitS"öpened immediately;-andthathe did notwant-an-address 
1368on the checks written out of the account. Later that day, another employee at First Republic 
1369emailed Cohen account opening paperwork to complete. Cohen returned the account opening 
1370documents partially completed, but failed to provide a copy ofhis driver's license or passport, and 
1371did not respond to the employee's question of how he wanted to fund the account. As a result, the 
1372account was never opened. 
1373c. On October 17, 2016, Cohen incorporated Essential Consultants LLC in Delaware. 
1374That same day, he filed paperwork to dissolve Resolution Consultants LLC. 
137536. Despite these steps taken by Cohen, it appears that the negotiation between Cohen 
1376and Davidson was not progressing sufficiently fast enough for Davidson or his client, Clifford, 
1377and they threatened to go public with Clifford's allegations just days before the presidential 
1378election. Specifically, based on my review of toll records, information obtained pursuant to the 
1379iCloud Warrant, and public sources, I know the following: 
1380a. According to an article in The Washington Post, which quoted emails sent from 
1381Cohen's email account hosted by the Trump Organization, on October 17, 2016, Davidson emailed 
1382Cohen and threatened to cancel the aforementioned "settlement agreement" by the end of the day 
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1388if Cohen did not complete the transaction? According to the article, Davidson sent Cohen a 
1389second email later in the day that stated in patt, "Please be advised that my client deems her 
1390settlement agreement canceled and void." At 4:00 p.m. that day, Cohen called Davidson and they 
1391spoke for over five minutes. 
1392b. Cohen's 4:00 p.m. call with Davidson and/or Davidson's threats to cancel the 
1393"settlement agreement" appear to have touched Offa flurry ofcommunications about the settlement 
1394agreement andÄQhéihéFCliffOiWwOUIWgo pubhc. Specifical 
1395i. 
1396At 4:43 p.m., Howard sent Cohen a text message that stated: "I'm told 
1397they're going with DailyMaiI. Are you aware?" One minute later, Cohen responded: "Call me." 
1398Based on my involvement in this investigation, I understand Howard's text to mean that he heard 
1399that Clifford was going to take her story of an extramarital affair with Trump to the Daily Mail, a 
1400tabloid newspaper. 
1401ii. 
1402At 4:45 p.m., Howard called Cohen and they spoke for over two minutes. 
1403Moments later, Davidson and Cohen spoke for about two minutes. 
1404iii. 
1405At 5:03 p.m., Cohen attempted to call Trump, but the call only lasted eight 
1406seconds. This was Cohen's first call after he spoke with Davidson. 
1407iv. 
1408At 5:25 p.m., Cohen texted Howard, stating: "Well???" 
1409At 6:44 p.m., Howard responded to Cohen's text, stating: "Not taking my 
1410calls." Cohen responded one minute later: "You're kidding. Who are you trying to reach?" 
1411Howard responded one minute later: "The 'agent."' Based on my involvement in this 
141229 Due to the partially covert nature of the investigation to this date, the USAO has not requested 
1413documents from the Trump Organization or Davidson, and thus does not possess the email 
1414referenced in this article. 
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1420investigation, I understand Howard 's text messages to mean that he attempted to contact Davidson 
1421about the matter involving Clifford, but that Davidson was not taking Howard's calls. 
1422vie 
1423At 6:49 p.m., Cohen called Howard and they spoke for nearly four minutes. 
1424c. The following day, on October 18, 2016, TheSmokingGun.com, a website that 
1425publishes legal documents and mugshots, published an article called: "Donald Trump and the Porn 
1426Superstar," which alleged that Trump had an extramarital affair with Clifford. However, the 
1427article noted that Clifford had declined to comment. 
142837. On or about October 25, 2016, the communications between Cohen, Davidson, 
1429Howard and Pecker picked up again, apparently concerning a transaction involving Clifford. 
1430Specifically, based on my review oftoll records, information obtained pursuant to the Cohen Email 
1431Warrants and iCloud Warrant, as well as my review ofpublic sources, I have learned the following: 
1432a. On October 25, 2016, at 6:09 p.m., Howard sent Cohen a text message stating: 
1433"Keith calling you urgently. We have to coordinate something on the matter he's calling you about 
1434or its [sic] could look awfully bad for everyone." One minute later, Davidson sent Cohen a text 
1435message stating "Call me." Cohen and Davidson called each other several times over the next half 
1436hour but appear not to have connected. At 6:42 p.m., Cohen and Davidson spoke for about eight 
1437minutes. At 7:11 p.m., they spoke for another two minutes. 
1438b. The next morning, on or about October 26, 2016, at 8:26 a.m., Cohen called Trump 
1439and spoke to him for approximately three minutes. At 8:34 a.m., Cohen called Trump again and 
1440connected for a minute and a half. 
1441c. At approximately 9:04 a.m.—less than thirty minutes after speaking with Trump— 
1442Cohen sent two emails to the person who had incorporated Resolution Consultants and Essential 
1443Consultants for him, and stated "can you send me asap the filing receipt" and then, in the second 
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1449email, "for Essential Consultants LLC." That person responded with the filing receipt two minutes 
1450later at 9:06 a.m. and with the certification of formation 23 minutes later, at 9:27 a.m. 
1451d. Shortly after that, Cohen contacted First Republic Employee-2 and told him, in sum 
1452and substance, that he decided not to open an account in the name of "Resolution Consulting" and 
1453instead would be opening a real estate consulting company in the name of "Essential Consultants." 
1454Cohen told First Republic Employee-2 that he was at Trump Tower, and wanted to go to a First 
1455Republic branch across the street to open the account, so Irs€RepubliéEmp10yee-2 called-First—— 
1456Republic Employee-I, a preferred banker at that branch, assist Cohen. At 11:00 a.m., First 
1457Republic Employee-I called Cohen. I know from my participation in an interview with First 
1458Republic Employee-I , that around the time ofthe call he went to Cohen's office in Trump Tower— 
1459on the same floor as the Trump Organization—and went through account opening questions, 
1460including know your customer questions, with Cohen. In response to a series of know-your- 
1461customer questions about the purpose of the account—-the answers to which First Republic 
1462Employee-I entered into a form—Cohen stated, in sum and substance, that he was opening 
1463Essential Consultants as a real estate consulting company to collect fees for investment consulting 
1464work, and all of his consulting clients would be domestic individuals based in the United States. 
1465Based on my review of records obtained from First Republic, it appears that this account (the 
1466"Essential Consultants Accoun€') was created at a time between 11:00 a.m. and 1 p.m. 
1467e. At 1:47 p.m., Cohen called Davidson and they spoke for approximately two 
1468minutes. At approximately 1 :49 p.m., Davidson emailed Cohen wiring instructions for an attorney 
1469client trust account at City National Bank. 
1470f. After the Essential Consultants Account was opened on October 26, 2016, Cohen 
1471transferred $131,000 from a home equity line of credit that Cohen had at First Republic to the 
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1477Essential Consultants Account. Following the transfer, at approximately 4:15 p.m. on October 26, 
14782016, First Republic Employee-2's assistant emailed Cohen at his Trump Organization email 
1479address to tell him that the funds had been deposited into the Essential Consultants Account. 
1480Cohen forwarded that email to the Cohen Gmail Account and then forwarded it to Davidson. 
1481g. At 6:37 p.m., Cohen asked Pecker by text message, "Can we speak? Important." 
1482Cohen called Pecker at 6:49 p.m. and connected for thirty seconds. At 6:57 p.m., Cohen sent 
1483Howard a text message, stating: "Please call me. ImportanW.'S¯COhen CäIlCd-Howard-at8:00 p.m. 
1484and connected for about thirty seconds. At 7:06 p.m., Cohen called Pecker again and they spoke 
1485for nearly thirteen minutes. At 7:24 p.m., Howard sent a text message to Cohen that: "He said 
1486he'd call me back in 20 minutes. I told him what you are asking for his [sic] reasonable. I'll get 
1487it sorted." Approximately an hour later, at 8:23 p.m., Howard told Cohen by text message to 
1488"check your Gmail for email from my private account." In an email sent at 8:23 p.m. by Howard 
1489to Cohen and Davidson, with the subject line "Confirmation," Howard stated, "Thank you both 
1490for chatting with me earlier. Confirming agreement on: - Executed agreement, hand-signed by 
1491Keith's client and returned via overnight or same-day FedEx to Michael, - Change of agreement 
1492to reflect the correct LLC, - Transfer of funds on Thursday AM to be held in escrow until receipt 
1493of agreement." After receiving that email, at approximately 8:27 p.m., Cohen asked Howard by 
1494text message, "Can you and David [Pecker] give me a call." Howard promptly responded: "David 
1495is not around I think. I'll call." At 8:28 p.m., Howard called Cohen and they spoke for three 
1496minutes. 
149738. On October 27, 2016, Cohen made a payment to Davidson of $130,000—with the 
1498funds intended for Clifford—for the purpose of securing her ongoing silence with respect to the 
1499allegations that she had an extramarital affair with Trump. Specifically, based on my review of 
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1505toll records, bank records, and information obtained pursuant to the iCloud Warrant and Cohen 
1506Email Warrants, I have learned the following: 
1507a. At 9:47 a.m., Cohen sent Davidson an email, stating: "Keith, kindly confirm that 
1508the wire received today, October 27, 2016 shall be held by you in your attorney's frust account 
1509until such time as directed for release by me, in writing. Additionally, please ensure that all 
1510paperwork contains the correct name of Essential Consultants LLC. I thank you in advance for 
1511your assistance and look forward to hearing from-j6ii1ater." 
1512b. At approximately 10:01 a.m., according to records provided by First Republic 
1513Bank, Cohen completed paperwork to wire $130,000 from the Essential Consultants Account— 
1514which had been funded a day prior from Cohen's home equity line of credit—to the attorney client 
1515trust account at City National Bank that Davidson had specified in the wiring instructions he sent 
1516to Cohen. The wire transfer was made shortly thereafter. 
1517c. At 10:02 a.m., Davidson responded to Cohen's email from 9:47 a.m., stating: "I 
1518confirm that I will work in good faith & that no ftnds shall be disbursed unless & until the plaintiff 
1519personally signs all necessary settlement papenvork, (the form of which will match the prior 
1520agreement). The settlement docs will name the correct corporation, (Essential Consultants LLC). 
1521Plaintiff s signature will be notarized and returned to you via FedEx. Only after you receive FedEx 
1522will I disburse. Fair?" 
1523d. At 10:50 a.m., First Republic Employee-I sent Cohen an email confirming that the 
1524payment had been sent and providing him with the wire number. 
152539. On October 28, 2016, and the days that followed, Cohen finalized the transaction 
1526with Davidson. Specifically, based on my review of toll records, information obtained pursuant 
1527to the iCloud Warrant, public sources, and bank records, I know the following: 
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